I am concerned the proposed…

I am concerned the proposed changes to the Aggregate Resources Act (ARA) will weaken oversight, reduce municipal authority, and increase risks to communities and the environment.

1. Undermining Municipal Planning:
 The proposal allows the Ministry of Natural Resources to make land use decisions independently of the Planning Act, reducing the influence of municipal official plans and zoning bylaws. Planning decisions must remain with the municipalities.

2. Lack of Cumulative Impact Assessment:
 There are no clear requirements to assess or mitigate the combined effects of multiple aggregate operations in the same area. This is currently a major problem with two applications currently underway in Lanark Highlands on the Highland Line. A new proposal (Highland Line Pit) and an expansion/amendment to an existing pit (McKinnon Pit) are both currently requesting below water extraction and are in the same 4km stretch as 3 other pits, a waterfront community and large maple syrup operations. Cumulative impacts need to be thoroughly evaluated.

3. Insufficient Environmental Protections:
 Water table studies are based on limited data, adverse effects are poorly defined, and dewatering impacts are not adequately addressed. Water reports should be more thorough not less and should be required for all new pits.

4. Weak Compliance and Transparency:
 There needs to be public access to non-compliance records and a stronger enforcement system, especially for repeat violators.

5. Loss of Important Policies:
 The plan to rescind 28 existing policies removes guidance on licensing, expansions, and MNR staff roles that would reduce clarity and accountability.

6. Inadequate Indigenous Consultation:
 The proposals do not ensure meaningful consultation with Indigenous communities, as required under Section 35 of the Charter. More needs to be done to ensure proper consultation.